NH: Entering apt building hallway to knock on door to tell def police were taking his gf to hospital didn’t violate REP or Jardines

Defendant’s girlfriend was sitting bent over in the front yard of their apartment building (actually a rooming house with numbered and locked doors with a common hallway). She was under the influence of something and was going to the hospital. She called out defendant’s name, but he didn’t respond. The officers went through the commonly open front door into the hallway to tell defendant in Room 1 that his girlfriend was going to the hospital. The entry into the hallway was reasonable and violated no reasonable expectation of privacy. Jardines was not violated. The officer was not there for an investigative purpose. State v. Smith, 2017 N.H. LEXIS 5 (Jan. 31, 2017).

Defendant was a Canadian citizen who lived in both Canada and the Phillippines. He was indicted in the U.S. for selling prescription drugs from overseas without proper authority. He was arranging his surrender through the FPD in Minnesota when Canada revoked his passport and the Phillippines arrested him and held him in immigration detention. The DEA was there and observed the arrest. Defendant offered an inoperable hard drive to the DEA because he believed it would help him. When it was delivered, there were two others that worked with it, and he assented to the DEA having them, too. When he arrived at LAX he was arrested, and he consented further to searches of the hard drives and computers. There was probable cause for a search warrant for defendant’s email accounts, too. United States v. Lachlan, 2016 U.S. Dist. LEXIS 183199 (D. Minn. Dec. 23, 2016),* adopted, United States v. Lachlan, 2017 U.S. Dist. LEXIS 13283 (D.Minn. Jan. 30, 2017).*

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